CLA-2-85:OT:RR:NC:N4:109
Daniel P. Swartz
Ryan Drawback Services, LLC.
500 Capital Mall
Suite 2250
Sacramento, CA 95814
RE: The tariff classification of a modular utility-scale photovoltaic substation from Canada
Dear Mr. Swartz:
In your letter dated February 21, 2017, you requested a tariff classification ruling on behalf of your client, Canadian Solar Solutions Inc.
The merchandise concerned is referred to as a modular utility-scale photovoltaic substation. As explained within your request, a substation is a place where electrical current is altered/changed as it passes through on its way from a power plant to the grid (homes/businesses).
The modular substations are produced in a factory on skids that can be transported on flat-bed trucks to the power generation site. Modular substations are pre-engineered, fabricated and tested prior to delivery to a solar or wind power generation site.
The substations are comprised of the following major components:
Recombiner: This component takes several direct current (DC) powered wired connections from a solar panel array and combines them into an aggregated DC output. That output is then used as the input for a DC to AC inverter. The recombiner is connected to the inverter via a 3000A solid copper bus-bar.
Base Skid: This component is a welded metal base skid, built on I-beams, with welded steel cover plates. It incorporates cut-outs with steel cover plates for access to DC cables for the recombiner and step-up transformer. It has open windows for the control cables to the auxiliary power panel. It’s painted with a special engineered two component epoxy primer and two component polyurethane top coat or hot-dipped galvanized.
Inverter: This component changes the direct current (DC) from the recombiner to alternating current (AC) which is then fed to a transformer. It connects to the transformer via 3000A flexible bus-bar or via cables.
Transformer: This component increases the AC power from low to high voltage. It’s a 2MVA pad mounted oil filled transformer. It connects to the inverter via a 3000A flexible bus-bar or via cables. The transformer has load break and fuses on the primary with a five tap positions primary switch.
Auxiliary Power Panel: This panel made of welded steel or various assembled steel profiles and painted or galvanized to match base skid. It typically includes: 60-A fused disconnect, two (2) 100A-3 phase panel boards, one 480/270V panel-board for the motor-tracker, and one 208/120V panel board for miscellaneous loads, data controller, and a SCADA drop-box. It’s configured either with one-or-two motor controllers depending upon client specification. It utilizes PVC or EMT conduits and requires copper wiring. |
All of the above major components will be received by Canadian Solar into its factory and affixed to the skid. Certified Canadian Solar electricians will perform the wiring between the various components, including the construction of the breaker/fuse panels for the auxiliary power panel in the factory. The inverter generally accounts for 64% of the total value of the modular.
The item concerned would be considered a composite machine as is provided for by Section XVI Note 3. Composite machines consist of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary functions are to be classified as if consisting only of that component or as being that machine which performs the principal function.
Based on the information supplied the item concerned would be considered a static converter. The Explanatory Notes to heading 8504 explains that static converters are apparatus used to convert electrical energy in order to adapt it for further use. They may incorporate converting elements of different types. They may also incorporate various auxiliary devices such as transformers, inductor coils, resistors, command regulators, etc. The function of changing the DC generated current into the required AC current would be the primary function of this device. As such the inverter would impart the principal function to this composite machine.
The applicable subheading for the modular utility-scale photovoltaic substation will be 8504.40.9570, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric transformers, static converters and inductors…: Static converters: Other: Inverters.” The general rate of duty will be 1.1%.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division